Common use of Fiscal Residence Clause in Contracts

Fiscal Residence. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature.

Fiscal Residence. 1. For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature.

Fiscal Residence. 1. For the purposes purpose of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation or management or any other criterion of a similar nature.

Fiscal Residence. 1. For 1.For the purposes of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management management, place of incorporation or any other criterion of a similar nature.

Fiscal Residence. 1. For the purposes of this AgreementConvention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. But this term does not include any person who is liable to tax in that State in respect only of income from sources in that State.

Fiscal Residence. (1. For the purposes of ) In this AgreementConvention, the term "resident of a Contracting State" means any person who, who under the laws of that State, State is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar nature. For purposes of United States tax, in the case of a partnership, estate, or trust, the term applies only to the extent that the income derived by such person is subject to United States tax as the income of a resident, either in its hands or in the hands of its partners or beneficiaries.

Fiscal Residence. (1. ) For the purposes of this Agreement, the term "“resident of a Contracting State" means any person who, under the laws of that Statestate, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of management or any other criterion of a similar naturenature .

Fiscal Residence. 1. For the purposes purpose of this Agreement, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of incorporation or management or any other criterion of a similar nature. 2. Where by reason of the provisions of paragraph 1 of this Article an individual is a resident of both Contracting States, then his status shall be determined in accordance with the following rules: